p120557.eng

INITIAL REVIEW ENGINEERING REPORT PMN: 12-0557 Focus Ready Draft 1/3/2013

ENGINEER: Austin \ JAS PV (kg/yr): 1,635,598 YX

SUBMITTER: Green Carbon

USE: Feedstock for oil refining.

OTHER USES: Analog is used as a fuel for industrial boilers, a marine fuel for ocean going vessels, a solvent used as industrial degreaser or dissolving agent used in aiding chemical reactions for manufacturing purposes, and an oil extender used in custom blending of oils. Analog is used as a cutter stock for Fuel Oil No.6 for industrial boilers of for marine diesel oil for marine engines. Analog is used as a gasification feedstock for producing CO and H2, as a feedstock to be distilled for petroeleum products, and to generate clean energy from waste tires.

MSDS: Yes Label: No

Gen Eqpt: impervious gloves are recommended / wear chemical safety glasses/ mechanical ventilation such as local exhaust as required to minimize exposure levels. Use explosion-proof equipment as required. Respirator: For operations where the occupational exposure limit may be exceeded or exposures are excessive, a NIOSH approved organic vapor respirator with organic vapor cartridges with dust/mist pre-filters or supplied air respirator is recommended. Equipment selection depends on contaminant type and concentration, select in accordance with OSHA 1910.134, ANSI Z88.2, and good industrial hygiene practice. Health Effects: Flammable liquid and vapor. Causes skin and eye irritation. May be absorbed through the skin in harmful amounts. Repeated skin exposure may cause dryness or cracking. Inhalation may cause irritation, headache, dizziness, and drowsiness. Harmful or fatal if swallowed. Contains chemicals that may cause cancer. TLV/PEL: TVR Oil (PMN) 100 % 5 mg/m3 TWA OSHA PEL (as mineral oil dust)

CRSS : Chemical Name:

S-H20: g/L @ VP: 1.7E+2 torr @ MW: 78.00 %<500 %<1000 Physical State and Misc CRSS Info: Neat: Liquid Mfg: Liquid Proc/Form: Solution: <1% PMN material in naphtha, kerosene, diesel fuel, and gasoline End Use: Destroyed. The structures shown on page 1 of Page 1p120557.eng this report are representative. The submiter provided analyses of two samples of the PMN material, showing product distributions of

The molecular weight shown above is for the low weight component . Submitted Properties: BP = 66-510 ¦C; VP = 0.3 torr (Sub. Est.); Density = 0.9 g/cc; Viscosity = 3.48 cSt; Flash Point = 88 ¦F (Sub. Est.). Properties for : MP = -153.7 ¦C (PhysProp); BP = 60. 2 ¦C (PhysProp); VP = 211 torr (PhysProp); WS = 0.014 g/L (PhysProp); logP = 3.21 (EPI). Properties for methylcyclopentane: MP = -142.5 ¦C (PhysProp); BP = 71.8 ¦C (PhysProp); VP = 1385 torr (PhysProp); WS = 0.042 g/L (PhysProp); logP = 3.37 (PhysProp). Continued on page 6 of this report.

Consumer Use: No

SAT (concerns) (12/21/2012): Related Cases and Related Cases and Misc SAT Info: Ecotox Related Cases: Migration to groundwater: negl-mod PBT rating: P3B3T1 P Rating: 1-3 // B Rating: 1-3 Health: 1-2 Dermal, Inhalation Eco: 2 Water (All releases to water with a CC = 360 ppb.)

OCCUPATIONAL EXPOSURE RATING: 2-3C

NOTES & KEY ASSUMPTIONS: Generated by the 06/07/2005 version of ChemSTEER.

POLLUTION PREVENTION CONSIDERATIONS:
None.

EXPOSURE-BASED REVIEW: Yes (2 criteria met)

1) # of workers exposed: 126 >1000? No Page 2p120557.eng 2) >100 workers with >10 mg/day inhalation exposure: Yes 3) (a) >100 workers w/1-10 mg/day inh. exp. & >100 days/yr: No (b) Routine Dermal Cont: >250 workers & >100 days/yr:

Yes

INITIAL REVIEW ENGINEERING REPORT CBI: Yes PMN: 12-0557

Manufacturing: Batch

Number of Sites/ Location:

Process Description: Rubber tire feedstock added to reactor --> Reactor is heated to 750 degrees and F --> Gas vapors are pulled from the reactor under vacuum --> Vapors are condensed in two streams (heavy oild and light oil) --> The heavy and liight oils are stored in separate 2000-5000 gallon tanks --> PMN (heavy and light oils), 100%) is pumped into 5000 gal tanker trucks (submission).

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY IRER Note: The daily releases listed for any source below may coincide with daily releases from the other sources to the same medium.

Water Central Tendency: 7.7E-1 kg/site-day over 1 day/yr from 6 sites

to: from: Equipment Cleaning Losses of Liquids from a Single, Large Vessel basis: EPA/OPPT Single Vessel Residual Model, CEB standard 1% residual. Spoke with submitter, vapor build up cleaned one per year.

Air Typical: 7.7E-1 kg/site-day over 248 days/yr from 6 sites Worst Case: 7.7E-1 kg/site-day over 248 days/yr from 6 sites to: not assessed from: Loading Liquid Product into Tank Trucks basis: EPA/OAQPS AP-42 Loading Model. Note that this model is presented to calculate a vapor generation rate that is used for the inhalation exposure model. Air releases based on submitter information is used as more conservative. Also note that the VP for this PMN (168 torr) falls outside of the recommended vapor pressure range of 0.001-35 torr for this model.

Air Output 2: 2.0E+0 kg/site-day over 248 days/yr from 6 sites Page 3p120557.eng to: air from: Loading Liquid Product into Tank Trucks basis: User-Defined Loss Rate Model. The submission estimates 1 kg/batch is released to fugitive air during light oil processing and 1 kg/batch is released to stack air during storage and loading. The submisison also indicates that testing indicates that no flue gas scrubber or thermal oxidizer is required to meet emissions limits; therefore CEB assesses 100% of these releases directly to air. Note that these estimates are more conservative than the AP-42 loading model, which assesses release of 0.8 kg/site-day.

RELEASE TOTAL 5.3E+3 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 6 Basis:

Inhalation:

Exposure to Vapor (Class II) Typical: 3.7E+2 mg/day over 248 days/yr Worst Case: 1.1E+4 mg/day over 248 days/yr Number of workers (all sites) with inhalation exposure: 6 Basis: Loading Liquid Product into Tank Trucks; EPA/OPPT Mass Balance Model. Note that the VP for this PMN (168 torr) falls outside of the recommended vapor pressure range of 0.001-35 torr for this model. This model is presented as a conservative estimate. NOTE: The respirator class is: II. Gas/vapor (all substances in the gas form).

INHALATION MONITORING DATA REVIEW 1) Uncertainty (estimate based on model, regulatory limit or data not specific to industry): Yes 2)a) Exposure level > 1 mg/day? Yes

OR b) Hazard Rating for health of 2 or greater? 1-2 No Inhalation Monitoring Data Desired? Yes (both criteria met)

Dermal:

Exposure to Liquid at 100.00% concentration High End: 1.8E+3 mg/day over 248 days/yr Number of workers (all sites) with dermal exposure: 6 Basis: Loading Liquid Product into Tank Trucks; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

INITIAL REVIEW ENGINEERING REPORT PMN: 12-0557

Processing: Oil Blending

Number of Sites/ Location:

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Process Description: PMN (liquid, 100%) in tank trucks --> PMN blended with other recycled oils --> Filtration --> Loading (liquid, <1%) (per submission).

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY IRER Note: The daily releases listed for any source below may coincide with daily releases from the other sources to the same medium.

Water High End: 4.5E-1 kg/site-day over 4 days/yr from 20 sites

to: from: Equipment Cleaning Losses of Liquids from a Single, Large Vessel basis: EPA/OPPT Single Vessel Residual Model, CEB standard 1% residual. Spoke with submitter, process fuel blends cleans single gracity drained tank quarterly.

Water or Incineration or Landfill High End: 3.8E+1 kg/site-day over 4 days/yr from 20 sites or 3.0E+3 kg/yr to: uncertain from: Cleaning Liquid Residuals from Tank Trucks Used to Transport the Raw Material basis: EPA/OPPT Bulk Transport Residual Model, CEB standard 0.2% residual. Submission does not estimate releases.

Air Typical: 1.6E-1 kg/site-day over 365 days/yr from 20 sites Worst Case: 1.6E-1 kg/site-day over 365 days/yr from 20 sites to: air from: Unloading Liquid Raw Material from Tank Trucks basis: EPA/OAQPS AP-42 Loading Model. Note that the VP for this PMN (168 torr) falls outside of the recommended vapor pressure range of 0.001-35 torr for this model.

Air Typical: 1.6E-1 kg/site-day over 365 days/yr from 20 sites Worst Case: 1.6E-1 kg/site-day over 365 days/yr from 20 sites to: air from: Loading Liquid Product into Tank Trucks basis: EPA/OAQPS AP-42 Loading Model.

RELEASE TOTAL 7.7E+3 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 60 Basis:

Inhalation:

Page 5p120557.eng Exposure to Vapor (Class II) Typical: 7.6E+1 mg/day over 250 days/yr Worst Case: 2.3E+3 mg/day over 250 days/yr Number of workers (all sites) with inhalation exposure: 60 Basis: Unloading Liquid Raw Material from Tank Trucks; EPA/OPPT Mass Balance Model. Note that the VP for this PMN (168 torr) falls outside of the recommended vapor pressure range of 0.001-35 torr for this model. This exposure is presented as a conservative estimate. NOTE: The respirator class is: II. Gas/vapor (all substances in the gas form).

INHALATION MONITORING DATA REVIEW 1) Uncertainty (estimate based on model, regulatory limit or data not specific to industry): Yes 2)a) Exposure level > 1 mg/day? Yes

OR b) Hazard Rating for health of 2 or greater? 1-2 No Inhalation Monitoring Data Desired? Yes (both criteria met)

Dermal:

Exposure to Liquid at 100.00% concentration High End: 1.8E+3 mg/day over 250 days/yr Number of workers (all sites) with dermal exposure: 60 Basis: Unloading Liquid Raw Material from Tank Trucks; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

INITIAL REVIEW ENGINEERING REPORT PMN: 12-0557

Number of Sites/ Location:

Process Description: Rubber tire feedstock added to reactor --> Reactor is heated to 750 degrees and F --> Gas vapors are pulled from the reactor under vacuum --> Vapors are condensed in two streams (heavy oild and light oil) --> The heavy and liight oils are stored in separate 2000-5000 gallon tanks --> PMN (light oil, 100%) is pumped into 5000 gal tanker trucks (submission).

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY IRER Note: The daily releases listed for any source below may coincide with daily releases from the other sources to the same medium.

Water or Incineration or Landfill High End: 4.5E-1 kg/site-day over 365 days/yr from 20 sites or 3.3E+3 kg/yr to: uncertain Page 6p120557.eng from: Cleaning Liquid Residuals from Tank Trucks Used to Transport the Raw Material basis: EPA/OPPT Bulk Transport Residual Model, CEB standard 0.2% residual. The submission does not discuss releases.

Air Typical: 1.6E-1 kg/site-day over 365 days/yr from 20 sites Worst Case: 1.6E-1 kg/site-day over 365 days/yr from 20 sites to: air from: Unloading Liquid Raw Material from Tank Trucks basis: EPA/OAQPS AP-42 Loading Model.

RELEASE TOTAL 5.6E+3 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 60 Basis: The submission does not provide worker estimates. CEB assumes a minimum of 3 workers/site.

Inhalation:

Exposure to Vapor (Class II) Typical: 7.6E+1 mg/day over 250 days/yr Worst Case: 2.3E+3 mg/day over 250 days/yr Number of workers (all sites) with inhalation exposure: 60 Basis: Unloading Liquid Raw Material from Tank Trucks; EPA/OPPT Mass Balance Model. NOTE: The respirator class is: II. Gas/vapor (all substances in the gas form).

INHALATION MONITORING DATA REVIEW 1) Uncertainty (estimate based on model, regulatory limit or data not specific to industry): Yes 2)a) Exposure level > 1 mg/day? Yes

OR b) Hazard Rating for health of 2 or greater? 1-2 No Inhalation Monitoring Data Desired? Yes (both criteria met)

Dermal:

Exposure to Liquid at 1.00% concentration High End: 1.8E+1 mg/day over 250 days/yr Number of workers (all sites) with dermal exposure: 60 Basis: Unloading Liquid Raw Material from Tank Trucks; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

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